Darren Gove Division of Water Pollution Control, Permit Section Illinois EPA 1021 N. Grand Ave. East PO Box 19276 Springfield, IL 62794-9276

Dear Mr. Gove: Environmental Review, Inc. has reviewed the document, we have the following comments:

1) Fact Sheet Page 2 – The dam demolition work is described as being accomplished with barge-mounted excavators with impact breakers, vibratory hammers, and explosives. The U.S. Army Corps of Engineers Section 401 Certification "Project Description for Fact Sheet" section, first paragraph, last sentence identified that a wire saw could be used instead of explosives. Since the "Summary of Comments of the Illinois Department of Natural Resources, Regional Planning Commissions, Zoning Boards or Other Entities" section identified that 4 Endangered Species are present and a nature preserve is located nearby, please do not authorize the use of explosives for this project in order to avoid disturbing the Endangered Species and nature preserve.

2) The U.S. Army Corps of Engineers Section 401 Certification, pages 13-14 made a determination that the project “may affect but not likely adversely affect” Threatened or Endangered Species (including the Gray Bat, Indiana Bat, Northern Long-eared Bat, Least Tern, Clubshell, Fanshell, Fat Pocketbook, Northern Riffleshell, Orangefoot Pimpleback, Purple Cat’s Paw, Rabbitsfoot, Ring Pink (mussel), Rough Pigtoe, Sheepnose Mussel, and Spectaclecase (mussel)) however at page 14 section (8) Actions to Minimize Impacts failed to consider eliminating the use of explosives to mitigate affects to the species. Therefore, the Illinois EPA should require the U.S. Army Corps of Engineers to revise the evaluation so that it is more protective of those species by removing the explosives method of demolition (especially since an alternative method using the wire saw may be employed instead (as described in comment 1 above).

3) The U.S. Army Corps of Engineers Section 401 Certification at page 16 – Applicable Toxic Effluent Standard of Prohibition Under Section 307 of the Clean Water Act section includes a statement that the “proposed demolition would not violate Section 307 of the Clean Water Act” however that statement appears to be unsupported. Since dioxins were identified to be present in the river sediments, are extremely toxic and the project involves incidental dredging, a technical evaluation should be completed. Please require a revision to identify the effluent standards that must be met and describe what engineering controls will be employed to meet the standard if necessary.

When responses to these comments are available, please email those to me at This email address is being protected from spambots. You need JavaScript enabled to view it. .

Thank you, Tom Price-Director, Environmental Review, Inc., 1792 Rogers Ave, San Jose, California 95112 www.envreview.org